Exporting e-scrap to Asia What to consider as the generator of the - PowerPoint PPT Presentation

Exporting e-scrap to Asia What to consider as the generator of the material Neil Peters-Michaud September 24, 2019 Photo credit: Cascade

Legal, ethical, practical export  How the laws apply to exporters  Reputation protection, for you and your clients  Emerging international law - SEERA Photo credit: Cascade CONFERENCE | September 24, 2019 | Orlando, Florida 2

Legally getting material out of the U.S. U.S. Principal Party of Interest Forwarding Agent The U.S. firm shipping the material (Cascade) Freight forwarder managing declarations and filings  Relates to shipments of recyclable  Power of attorney materials or used equipment  Completes and files Electronic Export  Standard or routed export Information in the Automated Export transactions System (AES)  Maintain documentation  Coordinates with the Foreign Principal Party of Interest / ultimate  Provide info to forwarding agent consignee  Screen parties in transaction CONFERENCE | September 24, 2019 | Orlando, Florida 3

Legally getting material into another country Exporter of Record Importing Country Legal Authority Foreign principal party of interest “buying” material Considerations of importing country requirements  Accepts responsibility for export  Is the material accepted for import? clearance − Consider transit countries as well − Domestic laws and multi-lateral agreements  Authorizes a forwarding agent to − Are items declared consistent with tariff facilitate the export codes and importing country requirements?  Responsible for importation  Is the ultimate consignee authorized documentation and clearance and/or licensed to process materials?  Approved to accept material CONFERENCE | September 24, 2019 | Orlando, Florida 4

Where to go for more information cascade-assets.com/resale/intlshipments.html www.bis.doc.gov/index.php/exporter-portal CONFERENCE | September 24, 2019 | Orlando, Florida 5

Where to go for more information Trusted, resourceful, hard working . . .broker Photo licensed to Cascade by Shutterstock CONFERENCE | September 24, 2019 | Orlando, Florida 6

Reputation Protection Safeguard the interests of your customers and you Are your broker and recycler legitimate? • Pre-qualification process • Verification of ongoing work • Properly “off-boarding” a cancelled processor Photo credit: Cascade CONFERENCE | September 24, 2019 | Orlando, Florida 7

Downstream Audit Tour the facility, if you can. Otherwise, get onsite information from a reliable source.  Fulfill e-Stewards or R2 requirements  Verify recycler’s capabilities to process material safely and effectively  Ensure recycler meets legal and other compliance requirements  Identify and consult local authorities  Check shipping records through intermediaries to final recovery  Review management systems  Also review broker’s programs and enlist their help in gathering evidence. CONFERENCE | September 24, 2019 | Orlando, Florida 8

Verify ongoing work  Collect shipping and receiving records  Track-Trace.com for container tracking  EarthEyeTrackers Photo credit: Cascade CONFERENCE | September 24, 2019 | Orlando, Florida 9

CASE STUDY Evaluate potential new processor Gather internal audit documents  listing overseas recyclers Follow the trail  Review shipping records − Destination facility is not on the list!?! − “Broker forgot to tell us about the change” Can recycler import plastic scrap?  − Malaysia crack down on imports − Only tariff code HS 3915 accepted − Importer must be licensed − Recycler must comply with Enviro Quality Act Photo credit: BAN, used under license agreement CONFERENCE | September 24, 2019 | Orlando, Florida 10

Secure E-Waste Export and Recycling Act (SEERA) HR 3559: Cook (R) and Espaillat (D) S 2448: Whitehouse (D) and Alexander (R) How to legally export:  Covers : computers, data center devices, mobile phones, monitors, TVs, printers . . .  Exporter registers with Commerce − Excludes: appliances, electronics in vehicles  Record each shipment in AES − Identify contents of shipment exported, destination  OK to export , if item is: countries, and consignee (capability)  Traceability and transparency − Tested, working − Shredded/destroyed items exported as a  Documentation accompanying shipments feedstock for direct reclamation − Declaration of compliance with law − Recalled by the manufacturer − Description of contents − Consignee permits and competence Personal items and devices not changing ownership − Importing country consent are exempt from regulation CONFERENCE | September 24, 2019 | Orlando, Florida 11

Navigating the process How can a domestic processor manage all this? Work with a broker or another domestic processor  Understand legal requirements  Manage risk appropriately  Use the standards as a guide  Audit and review regularly Photo credit: Cascade CONFERENCE | September 24, 2019 | Orlando, Florida 12

Avoid export problems - Do it . . . right Neil Peters-Michaud npm@cascade-assets.com 608-316-6637 www.cascade-assets.com Photo credit: Cascade CONFERENCE | September 24, 2019 | Orlando, Florida 13